This privacy policy (“Privacy Policy”) applies to personal data that I collect from you as a customer (“you” or “your”). It provides information on what data I collect, why I collect the data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”).

  1. Who I am 

I am Luke Bennett Photography, 6 Ladehead, Edinburgh, EH6 5TG. I am the data controller responsible for your personal data.

2.    What I collect- 

I collect the following information from you:

  • Personal information: This includes your name, address, e-mail address; phone number; as well as the names and other details about your family members and other participants in a photography session, together with and other information that you elect to provide to us.
  • Payment Information: Information about your debit/credit card and bank account information provided by you to our payment service providers, that I require for the purpose of processing payment for my goods and services.
  • Other Information: Personal details you choose to give when corresponding with me by phone or e-mail or in person.

In providing our services I create photographs which may identify you, your family members and other participants and that may be considered personal data. My photographs may be produced in print and digital format. You are responsible for ensuring that all participants in a photograph sessions have been provided with a copy of this privacy policy.

  1. HOW I USE YOUR PERSONAL INFORMATION - I use your personal information in the following ways:
  • to provide you with my services and to create and deliver the products you have requested and to contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and me.
  • As necessary for certain legitimate business interests, which include the following:
  • where I am asked to deal with any enquiries or complaints you make;
  • to provide postal communications which I think will be of interest to you;
  • if you ask me to delete your data or to be removed from my marketing lists, I am required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing; and
  • to (a) comply with legal obligations, (b) respond to requests from competent authorities; (b) protect my operations; (c) protect my rights, safety or property, and/or that of my affiliated businesses, you or others; and (d) enforce or defend legal rights, or prevent damage.
  • With your consent, I may use your photographs to promote and advertise my business, including (a) in my printed publications, presentations, promotional materials (including leaflets, brochures, stickers, bookmarks, posters, factsheets, calendars); (b) on our website and other digital advertising of our services; and (c) in social media forums such as Instagram, Pinterest and Facebook.
  • I may provide you with information about goods or services, events and other promotions I feel may interest you. I will contact you by email only with your consent, if this was given at the time you provided us with the personal data.
  • I may use your personal data for other purposes which you have consented to at the time of providing your data.

As used in this Privacy Policy, “legitimate interests” means my interests in conducting and managing my business. When I process your personal data for my legitimate interests, I make sure to consider and balance any potential impact on you, and your rights under data protection laws. My legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).


I share your personal data with third parties in the following situations:

  • Service Providers: I sometimes engage selected third parties who act on my behalf to support my operations, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable me to provide my goods/services, and (iii) providers of specialist services, including retouching, printers, framers and book binders. Pursuant to my instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
  • Business Transfers: if I sell my business or my company assets are acquired by a third party personal data held by us about our customers may be one of the transferred assets.
  • Administrative and Legal Reasons: if I need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms & Conditions or other applicable contract terms that you are subject to; (iii) to protect us, our members or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

Any credit/debit card payments and other payments you make will be processed by my third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that I do not myself directly process or store the debit/credit card data that you submit.


Your personal data will be transferred to and stored in countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area (“EEA”) to our service providers for the purposes described above.

Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where I transfer your personal data to countries outside of the EEA I will take all steps to ensure that your personal data continue to be protected. I will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service providers’ Privacy Shield certification or implementing standard contractual clauses for data transfers. 


I will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, I retain your personal data as long as I hold onto the digital files after your photography session to enable further orders and we retain digital files of your photographs until I need to free up space or you ask us to delete them.. When you consent to receive marketing communications, I will keep your data until you unsubscribe. Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.


Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

  • Right of access: If you ask me, I will confirm whether I am processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, I may need to charge a reasonable fee. 
  • Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that I correct or complete it. If I shared your personal data with others, I will tell them about the correction where possible. If you ask me, and where possible and lawful to do so, I will also tell you with whom I shared your personal data so you can contact them directly.
  • Right to erasure: You may ask me to delete or remove your personal data, such as where my legal basis for the processing is your consent and you withdraw consent. If I shared your data with others, I will tell them about the erasure where possible. If you ask me, and where possible and lawful to do so, I will also tell you with whom we shared your personal data with so you can contact them directly. I may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
  • Right to restrict processing: You may ask me to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If I shared your personal data with others, I will tell them about the restriction where possible. If you ask me, and where possible and lawful to do so, I will also tell you with whom I shared your personal data so you can contact them directly.
  • Right to object: You may ask me at any time to stop processing your personal data, andI will do so:
  • If I am relying on a legitimate interest to process your personal data — unless I demonstrate compelling legitimate grounds for the processing or
  • If I am processing your personal data for direct marketing.
  • Right to withdraw consent: If I rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before I received notice that you wished to withdraw your consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way I handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns (you may find EU Data Protection Authorities’ contact information here).

If you wish to exercise any of these rights please contact me as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.


Questions, comments or requests regarding this Privacy Policy should be addressed to Luke Bennett Photography by emailing